On June 10, 2019, David Goulding was the Chief Compliance Officer (“CCO”) for The Nutmeg Group LLC (“Nutmeg”), an SEC registered investment adviser and general partner to 15 unregistered investment partnerships (“the Funds”). His responsibilities included valuing the Funds’ investments, preparing quarterly account statements for the Funds, and tracking the assets of the Funds.  David … Read More

On June 5, 2019, the SEC issued new rule adopting amendments to SEC Form CRS and issued an interpretative guidance.  The Form CRS Relationship Summary will require registered investment advisers and broker-dealers to provide retail investors with simple, easy-to-understand information about the nature of their relationship with their financial professional.  While facilitating layered disclosure, the … Read More

On June 4, 2019, the SEC charged a private fund manager in the mortgage-backed securities space has agreed to pay a $5 million penalty to settle charges stemming from compliance deficiencies that contributed to the firm’s failure to ensure that certain securities in its flagship fund were valued properly.  The fund manager’s chief investment officer … Read More

On May 28, 2019, the SEC charged Stephen Brandon Anderson with defrauding clients by overcharging advisory fees of at least $367,000. According to the SEC’s order, Anderson owned and operated River Source Wealth Management, LLC, a now-defunct registered investment adviser in North Carolina.  River Source’s primary revenue stream was customer advisory fees.  Customer agreements provided … Read More

On May 28, 2019, the SEC charged Sean Premock with devising a scheme to defraud investors and obtained money and property by means of false and fraudulent pretenses, representations, and promises. The indictment alleges that Premock raised approximately $1.3 million from his clients by making numerous misrepresentations, including that the clients would earn high rates … Read More

On May 23, 2019 the SEC issued a risk alert on safeguarding of customer information stored on cloud and other network storage solutions.  The Risk Alert identifies security risks and best practices associated with the storage of customer records and information by investment advisers and broker-dealers (collectively, firms) in the cloud and on other electronic … Read More

On May 23, 2019, in recognition of the one-year anniversary of the passage of The Senior Safe Act, the Securities and Exchange Commission, the North American Securities Administrators Association (NASAA), and the Financial Industry Regulatory Authority (FINRA) have issued a fact sheet to help raise awareness among broker-dealers, investment advisers, and transfer agents of the Act and … Read More

On May 6, 2019,  Corinthian Capital Group, LLC, Peter B. Van Raalte, and David G. Tahan settled an enforcement action. From at least April 2014 to February 2015, Corinthian misused the assets in a private equity fund, Corinthian Equity Fund II, LP (“CEF 2”) that it advised to the advantage of Corinthian and three of … Read More

On April 23, 2019, the SEC charged a formerly SEC-registered investment adviser CCM and its principal’s investment of $4 million on behalf of two funds they managed. In mid-August 2016, CCM and its founder and chief executive officer Bruce made a $4 million loan on behalf of the two funds to a Norwegian individual and … Read More

On April 19, 2019, the SEC charged Prosper Funding LLC with miscalculating and materially overstating annualized net returns to retail and other investors. According to the SEC’s order, from approximately July 2015 until May 2017, Prosper excluded certain non-performing charged off loans from its calculation of annualized net returns that it reported to investors. The order finds that, as a result, … Read More